The
statutory right to appeal from an assessment of real property
by a municipal board of assessment appeals is conditioned on
the property owner ‘‘mak[ing]
application'' to the Superior Court within two months
of the date the board mails notice of its action. See General
Statutes § 12-117a. The question presented by this case
is whether, for purposes of this limitation period, such
application is made upon the filing of the required appeal
documents in the Superior Court, or rather, when those appeal
documents have been served upon the taxing municipality. The
plaintiff, Chestnut Point Realty, LLC, appeals from the
judgment of the Appellate Court affirming the trial
court's dismissal of its municipal tax appeal due to
untimeliness.[1]Chestnut Point Realty, LLC v.East Windsor, 158 Conn.App. 565, 575, 119 A.3d 1229
(2015). The plaintiff claims that, under the plain language
of § 12-117a, its appeal was timely commenced upon the
filing of its appeal documents in the Superior Court, even
though the appeal was not served on the defendant, the town
of East Windsor (town), until a date beyond the expiration of
the two month appeal period. We disagree and, accordingly,
affirm the judgment of the Appellate Court.[2]

The
following procedural history is relevant. The plaintiff owns
real property in the town. After the property was assessed
for purposes of the October 1, 2012 grand list, the plaintiff
appealed to the Board of Assessment Appeals of the Town of
East Windsor (board) to request a reduction in the
property's assessed value. On April 29, 2013, the board
denied that request and, on May 1, 2013, the town's
assessor mailed notice of the board's decision to the
plaintiff.

On June
28, 2013, the plaintiff filed a complaint in the Superior
Court alleging that the property had been overvalued. The
complaint was accompanied by a citation and recognizance and
bore a return date of July 23, 2013. On July 10, 2013, a
marshal served the complaint, citation and recognizance on
the town. On July 17, 2013, the marshal filed the return of
service with the court. On August 14, 2013, the town filed a
motion to dismiss the appeal, arguing that the trial court
lacked subject matter jurisdiction because the plaintiff did
not serve the appeal papers on the town within the two month
period allotted by § 12-117a. After a hearing, the court
granted the town's motion and dismissed the appeal.

The
plaintiff thereafter appealed from the dismissal of its
appeal to the Appellate Court. The Appellate Court agreed
with the trial court that the appeal was untimely pursuant to
§ 12-117a because the plaintiff did not serve the town
within two months of the date that the board had mailed
notice of its decision denying a change to the assessment of
the plaintiff's property. Id. In support of its
decision, the Appellate Court relied on the plain language of
§ 12-117a, case law governing the commencement of a
civil action, public policy considerations and a number of
consistent holdings of the Superior Court to which, the
Appellate Court reasoned, the legislature presumably had
acquiesced. Id., 569-74. This appeal followed.

The
plaintiff claims that the Appellate Court improperly
interpreted § 12-117a to require the dismissal of its
appeal as untimely. In the plaintiff's view, §
12-117a clearly and unambiguously provides that an appeal
that is filed with the Superior Court within the two month
appeal period is timely, even if service of the appeal on the
town occurs after the two month period has run. The town, in
response, contends that the statute clearly and unambiguously
provides that the appeal, to be timely, must be served within
two months of the board's notice. We disagree with the
parties that the text of § 12-117a clearly and
unambiguously answers the question before us. We conclude,
after a thorough examination of the relevant interpretive
sources, that the town's construction of the statute is
the correct one. Accordingly, the Appellate Court properly
upheld the dismissal of the plaintiff's appeal as
untimely.

We
begin with the standard of review and well established
general principles. This case presents a question of
statutory construction, an issue of law over which we
exercise plenary review. Cales v.Office of
Victim Services, 319 Conn. 697, 701, 127 A.3d 154
(2015). In determining the meaning of a statute, we look
first to the text of the statute and its relationship to
other statutes. General Statutes§ 1-2z. If the text of
the statute is not plain and unambiguous, we may consider
extra-textual sources of information such as the
statute's ‘‘legislative history and
circumstances surrounding its enactment, to the legislative
policy it was designed to implement, and to its relationship
to existing legislation and [common-law] principles governing
the same general subject matter . . . .'' (Internal
quotation marks omitted.) Doe v.Boy Scouts of
America Corp., 323 Conn. 303, 332, 147 A.3d 104 (2016).
Our fundamental objective is to ascertain the
legislature's intent. Id.

The
right to appeal a municipal property tax assessment, like
other administrative appeals, derives from statute.
Atchison v.Newtown, 2 Conn.Supp. 142, 144
(1935) (‘‘[t]he entire subject of appeals from
assessment of property for purposes of taxation is statutory
in origin''). ‘‘[A] statutory right to
appeal may be taken advantage of only by strict compliance
with the statutory provisions by which it is created . . .
including the time periods prescribed in which to
appeal.'' (Citation omitted; internal quotation marks
omitted.) Reardon v.Zoning Board of
Appeals, 311 Conn. 356, 366, 87 A.3d 1070 (2014).
‘‘Such provisions are mandatory, and, if not
complied with, the appeal is subject to dismissal.''
(Internal quotation marks omitted.) Citizens Against
Pollution Northwest, Inc. v.Connecticut Siting
Council, 217 Conn. 143, 152, 584 A.2d 1183 (1991).
Consequently, a property owner who wishes to challenge an
assessment must follow the required procedures within the
time period allotted and, if he fails to do so, he forfeits
the right to pursue the available statutory remedies.
Danbury v.Dana Investment Corp., 249 Conn.
1, 12-15, 730 A.2d 1128 (1999).

We
begin by examining the statutory text. Section 12-117a
provides in relevant part: ‘‘Any person . . .
claiming to be aggrieved by the action of the board of tax
review or the board of assessment appeals, as the case may
be, in any town or city may, within two months from
the date of the mailing of notice of such action, make
application, in the nature of an appeal therefrom . . .
to the superior court for the judicial district in
which such town or city is situated, which shall be
accompanied by a citation to such town or city to appear
before said court. Such citation shall be signed by the same
authority and such appeal shall be returnable at the same
time and served and returned in the same manner as is
required in case of a summons in a civil action. . .
.'' (Emphasis added.) In the plaintiff's view,
the phrase ‘‘make application'' is
synonymous with the word ‘‘file, '' and,
therefore, the statute clearly and unambiguously provides
that, to meet the statutory deadline, an aggrieved taxpayer
is required only to file its appeal papers with the Superior
Court within the two month period. To the town, the statute,
by requiring service and return in the same manner as for
civil actions, is equally clear and provides, instead, that
service on the town must be effected within the two month
period. After close examination of the statutory language, we
are unable to agree with either party that it is clear and
unambiguous.

&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Simply
put, the statute does not provide that an aggrieved party
must &lsquo;&lsquo;file&#39;&#39; its application with the
court within two months, as it easily could have, and it is
not otherwise apparent that the terminology used instead,
&lsquo;&lsquo;make application, &#39;&#39; is equivalent.
Compare, e.g., General Statutes &sect; 4-183 (providing, in
subsection [a] that person aggrieved by final decision of
administrative agency &lsquo;&lsquo;may appeal to the
Superior Court, &#39;&#39; and, in subsection [c], that,
&lsquo;&lsquo;within forty-five days&#39;&#39; of one of
various triggering events, &lsquo;&lsquo;a person appealing
as provided in this section shall . . . [among other
requirements] file the appeal with the clerk of the
superior court&#39;&#39; [emphasis added]). Moreover,
although &sect; 12-117a indicates that service and return of
the appeal should proceed in accordance with the service and
return requirements governing civil actions generally, it is
silent as to when, in relation to the challenged board
decision, the service of process must occur. Compare, e.g.,
General Statutes (Supp. 2016) &sect; 8-8 (b) (providing that
person aggrieved by decision of zoning entity
&lsquo;&lsquo;may take an appeal to the superior
court&#39;&#39; and that &lsquo;&lsquo;[t]he appeal shall
be commenced by service of process . . . within fifteen
days from the date that notice of the decision was
published as [statutorily] required'' [emphasis
added]). Finally, although § 12-117a requires a property
owner to ‘‘make application'' to the
court within two months, it does not state explicitly what,
exactly, that phrase contemplates. Compare General Statutes
§ 12-242kk (a) (providing that, ‘‘within one
hundred eighty days'' after receiving condemnation
notice and ...

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